January 3, 2018 Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Columbia Gas Transmission, LLC 700 Louisiana Street, Suite 700 Houston, Texas 77002-2700 John A. Roscher Director, Rates & Tariffs tel 832.320.5675 fax 832.320.6675 email John_Roscher@TransCanada.com web www.columbiapipeinfo.com/infopost/ Re: Columbia Gas Transmission, LLC Change in FERC Gas Tariff Docket No. RP18- -. Dear Ms. Bose: Pursuant to Section 4 of the Natural Gas Act ( NGA ) and Part 154 of the Federal Energy Regulatory Commission s ( FERC or Commission ) regulations, 1 Columbia Gas Transmission, LLC ( Columbia ) respectfully submits for filing and acceptance revised Sections VII.Table-of- Contents, and VII.27 2 to be part of its FERC Gas Tariff, Fourth Revised Volume No. 1 ( Tariff ). As explained in greater detail below, Columbia is proposing revisions to Section VII.27 to update and clarify provisions regarding construction of facilities. Columbia respectfully requests that the Commission accept revised tariff Sections VII.Table-of-Contents, and VII.27, included herein as Appendix A, to become effective February 2, 2018. Correspondence The names, titles, mailing addresses, and telephone numbers of those persons to whom correspondence and communications concerning this filing should be addressed are as follows: 1 18 C.F.R. Part 154 (2018). 2 Specifically, Part VII, General Terms & Conditions, Table of Contents ( Section VII.Table-of-Contents ), and Part VII.27, General Terms & Conditions, Facilities Policy ( Section VII.27 ), are being revised in the instant filing.
* John A. Roscher Director, Rates & Tariffs Joan F. Collins Manager, Tariffs and Compliance Columbia Gas Transmission, LLC 700 Louisiana Street, Suite 700 Houston, Texas 77002-2700 Tel. (832) 320-5651 E-mail: joan_collins@transcanada.com * David R. Hammel Senior Legal Counsel Columbia Gas Transmission, LLC 700 Louisiana Street, Suite 700 Houston, Texas 77002-2700 Tel. (713) 320-5861 E-mail: dave_hammel@transcanada.com * Persons designated for official service pursuant to Rule 2010. Statement of the Nature, Reasons and Basis for Filing Within Section VII.27, Columbia is proposing to replace outdated legacy provisions regarding facility construction in their entirety with updated provisions that clearly state Columbia s policy with respect to the financing and construction of facilities, including whether Columbia will pay or contribute to the construction cost, consistent with Sections 154.109(b) and 284.7(f) of the Commission s regulations. 3 As revised, Section.VII.27 clarifies that Columbia shall not be required to construct new facilities, but, in the event Columbia agrees to build, operate, own, or contribute to the cost of such facilities, Columbia will do so on a not unduly discriminatory basis. The new language stipulates that unless otherwise agreed, Columbia may require a shipper to pay for all or a portion of the costs incurred for installing and/or operating new facilities, either in the form of an incremental rate, an operations fee, or a lump sum payment, including the tax-on-tax effect. Such changes are consistent with other pipelines tariff provisions previously approved by the Commission. 4 Additionally, Columbia is proposing to include language to accommodate the provision of contributions in aid of construction ( CIAC ) for shipper-owned facilities. Consistent with CIAC 3 18 C.F.R. Sections 154.109(b) and 284.7(f). 4 See Gas Transmission Northwest LLC, Part 6.18.6, GT&C Installation of Facilities. See also Bison Pipeline LLC, Part 6.19, GT&C Facilities Policy; Northern Border Pipeline Company, Part 6.19, GT&C Facilities Policy; and Tennessee Gas Pipeline Company, L.L.C., First Revised Sheet No. 366, Construction of Receipt and Delivery Facilities. 2
provisions approved by the Commission in other proceedings, 5 the proposed language reflects that Columbia may, on a non-discriminatory basis, pay for all or part of the cost of construction of a shipper s facilities if Columbia determines that it will be economically neutral to, or will economically benefit from, the CIAC. The flexibility to offer CIAC for shipper-owned facilities will provide Columbia with greater opportunities to maintain existing load and attract both new supply sources and new markets, and benefit Columbia s shippers who will have a greater range of gas supply alternatives and additional opportunities to serve new markets. Furthermore, Columbia will post any CIAC agreement on its internet website along with related terms and conditions, 6 and the accounting treatment for CIACs will be consistent with that previously approved by the Commission. 7 Further, Columbia is proposing to broaden Section VII.27 to incorporate the Commission s current interconnection policy, as set forth in the Panhandle Order. 8 The interconnect policy explicitly lists the five conditions that must be satisfied in order for a pipeline to grant an interconnect. 9 Additionally, to ensure Columbia is able to effectively operate its system after an interconnection has been installed, the proposed revisions give Columbia the right to require installation of any equipment necessary to accurately monitor the quality of gas received into its system at the interconnection, maintain the operational reliability of its system, and enable accurate custody transfer management. 5 Gas Transmission Northwest LLC, 148 FERC 61,216 (2014); Northern Border Pipeline Company, 101 FERC 61,092 (2002); Texas Gas Transmission, LLC, 128 FERC 61,104 (2009); and ANR Pipeline Company,138 FERC 61,247, order on reh g 140 FERC 61,181 (2012). 6 ANR Order at P 16. 7 ANR Order on Rehearing on PP 8-10. 8 Panhandle Eastern Pipe Line Company, 91 FERC 61,037 (2000) ( Panhandle Order ). 9 First, the shipper seeking the interconnection must be willing to bear the costs of construction or be willing to construct the interconnection in compliance with the pipeline s technical requirements. Second, the interconnect must not adversely affect the pipeline s operations. Third, the interconnection and any resulting transportation must not diminish service to the pipeline s existing customers. Fourth, the interconnection must not cause the pipeline to be in violation of any applicable environmental or safety laws or regulations with respect to the facilities required to establish an interconnection with the pipeline s existing facilities. Finally, the interconnection must not cause the pipeline to be in violation of its right-of-way agreements. When these conditions are met, a pipeline is unable to deny an interconnection. 3
Revised Section VII.Table-of-Contents, is submitted herein in Appendix A to reflect the name change to Section VII.27. Effective Date Columbia requests that the Commission accept the proposed tariff sections submitted in the instant filing to become effective February 2, 2018. Other Filings Which May Affect This Proceeding There are no other filings before the Commission that may significantly affect the changes proposed herein. Contents of Filing In accordance with Section 154.7 of the Commission s regulations, Columbia is submitting the following via its electronic tariff filing: 1. This transmittal letter; 2. The clean version of the tariff sections (Appendix A); and 3. The marked version of the tariff sections (Appendix B). Certificate of Service As required by Sections 154.7(b) and 154.208 of the Commission s regulations, copies of this filing are being served upon all of Columbia s existing customers and interested state regulatory agencies. A copy of this letter, together with any attachments, is available for public inspection during regular business hours at Columbia s principal place of business. Pursuant to Sections 385.2005 and 385.2011, the undersigned has read this filing and knows its contents, and the contents are true as stated, to the best of his knowledge and belief. The undersigned possesses full power and authority to sign such filing. 4
Any questions regarding this filing may be directed to Joan Collins at (832) 320-5651. Respectfully submitted, COLUMBIA GAS TRANSMISSION, LLC John A. Roscher Director, Rates & Tariffs Enclosures 5
Appendix A Columbia Gas Transmission, LLC FERC Gas Tariff, Fourth Revised Volume No. 1 Clean Tariff Tariff Sections Version VII.GT&C Table of Contents v.9.0.0 VII.27.GT&C Facilities Policy v.1.0.0
Part VII. Fourth Revised Volume No. 1 Version 9.0.0 Section 1 Definitions 2 Electronic Bulletin Board (EBB) 3 Requests for Service TABLE OF CONTENTS TO GENERAL TERMS AND CONDITIONS 4 Availability of Capacity for Firm Services 5 Service Agreement and Electronic Contracting 6 Nominating, Scheduling and Monitoring 7 Capacity Allocation 8 Meter Allocations 9 Operating Conditions 10 Billing and Payment 11 Flexible Primary and Secondary Receipt and Delivery Points 12 Maximum Daily Delivery Obligation at Delivery Points and Maximum Daily Quantity at Receipt Points 13 Delivery Pressure 14 Release and Assignment of Service Rights 15 Force Majeure 16 Interruptions of Service 17 Operational Flow Orders 18 Inventory Transfers 19 Penalties
Part VII. Fourth Revised Volume No. 1 Version 9.0.0 20 Discounting 21 Regulatory Fees 22 Possession of Gas 23 Warranty of Title to Gas 24 Warranty of Eligibility for Transportation 25 Gas Quality 26 Measurement 27 Facilities Policy 28 Schedules and Contracts Subject to Regulation and Revision 29 Notices 30 Complaint Resolution Procedure 31 Reserved for Future Use 32 Curtailment 33 Reserved for Future Use 34 Annual Charge Adjustment 35 Retainage Adjustment Mechanism (RAM) 36 Transportation Costs Rate Adjustment (TCRA) 37 Compliance with 18 CFR, Section 284.12 38 Reservation Charge Credits 39 Account No. 191 Reconciliation Mechanism 40 Segmentation Pooling 41 Recovery of Stranded Account No. 858 Costs
Part VII. Fourth Revised Volume No. 1 Version 9.0.0 42 Contract Demand Reduction Option 43 Storage Inventory Transfers 44 Electric Power Costs Adjustment (EPCA) 45 SFC Charge 46 Negotiated Rates 47 Offsystem Pipeline Capacity 48 Reimbursement of Sales and Use Taxes 49 Operational Purchases and Sales 50 Storage Service with Market-Based Rates 51 Gathering Affiliates(s) Standards of Conduct 52 Capital Cost Recovery Mechanism (CCRM) 53 Revenue Sharing
Fourth Revised Volume No. 1 VII.27. Facilities Policy Version 1.0.0 27. FACILITIES POLICY Transporter shall not be required to construct new facilities to provide either firm or interruptible transportation. In the event Transporter agrees to build, operate, own, or contribute to the cost of building any such facilities, Transporter shall do so on a not unduly discriminatory basis. 27.1 Shipper Reimbursement. Unless otherwise agreed to by Transporter, Shipper will be required to reimburse Transporter, on mutually agreeable terms, for all or a portion of Transporter s costs associated with construction and operation of facilities. Such mutually agreed upon reimbursement may be in the form of an incremental rate, an operations fee, a lump sum payment, or a mutually agreed upon method, including reimbursement for any associated tax effects. Transporter may waive this requirement on a not unduly discriminatory basis. 27.2 Transporter Contribution. Transporter may pay or contribute to all or a portion of the cost of building or operating facilities requested by current or potential Shippers if Transporter determines that such action will result in an economic benefit, or determines that the project is economically neutral to Transporter. Transporter will evaluate each prospective project under this policy based upon the incremental cost-of-service and the incremental revenues which Transporter estimates will be generated as a result of the project. When estimating incremental revenues to be generated, Transporter will base those revenues upon transportation rates it expects to be able to charge, net of any surcharges, and the incremental volumes or firm service contracts that will result from the project. Transporter may consider volumes or firm service contracts to be incremental if the volumes or firm service contracts that will be transported or provided, respectively, would not otherwise flow through or be contracted for firm service on Transporter s pipeline system. 27.3 Pipeline Interconnections. Transporter will have the right, regardless of which party designs and constructs the facilities, to require installation of any equipment necessary to: i) accurately monitor the quality of gas received into its facilities to ensure that such gas meets the specifications of its Tariff; ii) maintain the reliability and operational integrity of its facilities; and iii) enable accurate custody transfer management. In addition, any interconnection will be subject to the following conditions: a) The party seeking the interconnection must be willing to bear the costs of the construction if Transporter performs the task. In the alternative, the party seeking the interconnection could construct the facilities itself in compliance with Transporter s technical requirements; b) The proposed interconnection must not adversely affect Transporter s operations; c) The proposed interconnection and any resulting transportation must not diminish service to Transporter s existing customers; d) The proposed interconnection must not cause Transporter to be in violation of any applicable environmental or safety laws or regulations with respect to the facilities required to establish an interconnection with Transporter s existing facilities; and
Fourth Revised Volume No. 1 VII.27. Facilities Policy Version 1.0.0 e) The proposed interconnection must not cause Transporter to be in violation of its right-of-way agreements or any other contractual obligations with respect to the interconnection facilities.
Appendix B Columbia Gas Transmission, LLC FERC Gas Tariff, Fourth Revised Volume No. 1 Marked Tariff Tariff Sections Version VII.GT&C Table of Contents v.9.0.0 VII.27.GT&C Facilities Policy v.1.0.0
Part VII. Fourth Revised Volume No. 1 Version 9.0.0 Section 1 Definitions 2 Electronic Bulletin Board (EBB) 3 Requests for Service TABLE OF CONTENTS TO GENERAL TERMS AND CONDITIONS 4 Availability of Capacity for Firm Services 5 Service Agreement and Electronic Contracting 6 Nominating, Scheduling and Monitoring 7 Capacity Allocation 8 Meter Allocations 9 Operating Conditions 10 Billing and Payment 11 Flexible Primary and Secondary Receipt and Delivery Points 12 Maximum Daily Delivery Obligation at Delivery Points and Maximum Daily Quantity at Receipt Points 13 Delivery Pressure 14 Release and Assignment of Service Rights 15 Force Majeure 16 Interruptions of Service 17 Operational Flow Orders 18 Inventory Transfers 19 Penalties
Part VII. Fourth Revised Volume No. 1 Version 9.0.0 20 Discounting 21 Regulatory Fees 22 Possession of Gas 23 Warranty of Title to Gas 24 Warranty of Eligibility for Transportation 25 Gas Quality 26 Measurement 27 Construction of Facilities Policy 28 Schedules and Contracts Subject to Regulation and Revision 29 Notices 30 Complaint Resolution Procedure 31 Reserved for Future Use 32 Curtailment 33 Reserved for Future Use 34 Annual Charge Adjustment 35 Retainage Adjustment Mechanism (RAM) 36 Transportation Costs Rate Adjustment (TCRA) 37 Compliance with 18 CFR, Section 284.12 38 Reservation Charge Credits 39 Account No. 191 Reconciliation Mechanism 40 Segmentation Pooling 41 Recovery of Stranded Account No. 858 Costs
Part VII. Fourth Revised Volume No. 1 Version 9.0.0 42 Contract Demand Reduction Option 43 Storage Inventory Transfers 44 Electric Power Costs Adjustment (EPCA) 45 SFC Charge 46 Negotiated Rates 47 Offsystem Pipeline Capacity 48 Reimbursement of Sales and Use Taxes 49 Operational Purchases and Sales 50 Storage Service with Market-Based Rates 51 Gathering Affiliates(s) Standards of Conduct 52 Capital Cost Recovery Mechanism (CCRM) 53 Revenue Sharing
Fourth Revised Volume No. 1 VII.27. Facilities Policy Version 1.0.0 27. CONSTRUCTION OF FACILITIES POLICY- FACILITY CHARGE Transporter shall not be required to construct new facilities to provide either firm or interruptible transportation. In the event Transporter agrees to build, operate, own, or contribute to the cost of building any such facilities, Transporter shall do so on a not unduly discriminatory basis. 27.1 Shipper ReimbursementArrangement for Construction of Transmission Facilities. Unless otherwise agreed to by Transporter, Shipper will be required to reimburse Transporter, on mutually agreeable terms, for all or a portion of Transporter s costs associated with construction and operation of facilities. Such mutually agreed upon reimbursement may be in the form of an incremental rate, an operations fee, a lump sum payment, or a mutually agreed upon method, including reimbursement for any associated tax effects. Transporter may waive this requirement on a not unduly discriminatory basis.shipper may request Transporter to construct, maintain and operate, either all or a part of, the lateral line for the transportation of gas from Transporter's main transmission line to Shipper's markets, or when the delivery point to Shipper at Transporter's main transmission line is in close proximity to a compressor station of Transporter, Shipper may request Transporter to provide facilities to deliver gas to Shipper in excess of Transporter's main line operating pressure. If Transporter shall determine that the granting of such request by Shipper is necessary or desirable, that no undue burden will thereby be placed upon Transporter, and that no impairment of Transporter's ability to render adequate service to its shippers will result therefrom, Transporter will construct or provide such facilities if it can obtain proper, necessary authorization. 27.2 Transporter ContributionMethod of Payment. Transporter may pay or contribute to all or a portion of the cost of building or operating facilities requested by current or potential Shippers if Transporter determines that such action will result in an economic benefit, or determines that the project is economically neutral to Transporter. Transporter will evaluate each prospective project under this policy based upon the incremental cost-of-service and the incremental revenues which Transporter estimates will be generated as a result of the project. When estimating incremental revenues to be generated, Transporter will base those revenues upon transportation rates it expects to be able to charge, net of any surcharges, and the incremental volumes or firm service contracts that will result from the project. Transporter may consider volumes or firm service contracts to be incremental if the volumes or firm service contracts that will be transported or provided, respectively, would not otherwise flow through or be contracted for firm service on Transporter s pipeline system. 27.3 Pipeline Interconnections. Transporter will have the right, regardless of which party designs and constructs the facilities, to require installation of any equipment necessary to: i) accurately monitor the quality of gas received into its facilities to ensure that such gas meets the specifications of its Tariff; ii) maintain the reliability and operational integrity of its facilities; and iii) enable accurate custody transfer management. In addition, any interconnection will be subject to the following conditions:
Fourth Revised Volume No. 1 VII.27. Facilities Policy Version 1.0.0 a) The party seeking the interconnection must be willing to bear the costs of the construction if Transporter performs the task. In the alternative, the party seeking the interconnection could construct the facilities itself in compliance with Transporter s technical requirements; b) The proposed interconnection must not adversely affect Transporter s operations; c) The proposed interconnection and any resulting transportation must not diminish service to Transporter s existing customers; d) The proposed interconnection must not cause Transporter to be in violation of any applicable environmental or safety laws or regulations with respect to the facilities required to establish an interconnection with Transporter s existing facilities; and e) The proposed interconnection must not cause Transporter to be in violation of its right-of-way agreements or any other contractual obligations with respect to the interconnection facilities. (a) In the event Transporter shall provide a lateral line or other transmission facilities at the request of Shipper, Shipper will pay Transporter for the costs of such facilities by paying in addition to the amount paid for natural gas, a facility charge consisting of the sum of the following components: (1) Depreciation computed at the annual accrual rates being used by Transporter for booking depreciation expense applicable to such facilities; (2) Return computed at the latest rate allowed Transporter by Federal Energy Regulatory Commission in a formal rate determination applied to the original cost of the facilities less accrued depreciation and plus necessary working capital applicable to such facilities; (3) Taxes paid for the ownership and operation of such facilities; and (4) Operation and maintenance expenses applicable to such facilities. (b) The annual amount of the facility charge shall be established starting with the first day of the calendar month in which Transporter shall have completed or made available for operation the facilities requested by Shipper. Such amount shall be estimated by Transporter when the facilities are made available and at the beginning of each calendar year thereafter. Each month, Transporter will bill Shipper for one-twelfth of the estimated annual facility charge. An adjustment will be made if necessary at the end of each calendar year to reflect the cost applicable to said facilities for the year. 27.3 Agreement. In each case where Transporter agrees to construct facilities at the request of the Shipper, the Service Agreement will contain as an Exhibit thereto an agreement concerning such facilities, executed in the form as set forth in this Tariff.